What is SAF-T?

The Standard Audit File for Tax purposes (SAF-T) is a standardized file (in XML format) with the objective of allowing an easy export, and at any time, of a predefined set of accounting and invoicing records, in a readable and common version, independent of the program used, without affecting the internal structure of the program’s database or its functionality.

SAF-T file is an international standard defined by the OECD, although each country is allowed to make the necessary adaptations.

Its genesis has a clear and objective intention: to define a standard language for reporting tax information in order to facilitate the inspection activity.

How many SAF-T files are there in Portugal?

In Portugal, the Tax Authority requires the following SAF-T files:

• Integrated SAF-T (I) – includes all accounting and billing information.
• SAF-T Accounting (C) – includes account code, accounting transactions, customers, vendors, tax code and receipts.
• Billing SAF-T (F) – includes commercial documents to customers, clients, suppliers, products/services, tax code, movement of goods or provision of services and receipts.
• Self-invoicing (S) – includes only commercial documents to customers, clients, products/services and tax code.

When do SAF-T files have to be submitted?

Companies resident and non-resident in Portugal that primarily carry out an activity of a commercial, industrial or agricultural nature; organize their accounting using computerized means; and with organized accounting must make the SAF-T file related to accounting available to the Portuguese Tax Authority (AT) inspectors for inspection and from fiscal year 2023 onward, they must submit it annually through the AT Portal to automatically pre-populate Annexes A and I of the IES.

Companies residing in Portugal that had, in the previous calendar year, a turnover of more than €50,000, use invoicing software; and are required to have organized accounting or have chosen to do so, they must make the SAF-T file relating to invoicing available to the AT inspectors at the time of inspection and submit it by the 12th day of the month following the issuance of the invoice.

SAF-T Portugal, also known as Standard Audit File for Tax (PT), is a standardized electronic format for reporting VAT transactions in Portugal. It was introduced in 2008 to facilitate the electronic submission of VAT returns, accounting records, and transport documents.

Key Requirements

• Resident businesses: Mandatory annual reporting starting from 2026, with the first report due in 2027.
• Non-resident businesses: Mandatory monthly reporting, with the first report due in 2023.
• SAF-T Accounting file: Used to pre-fill the annual IES accounting and tax return.
• SAF-T Billing file: Used for monthly VAT returns, with submissions due by the 5th of each month.
• SAF-T Transport documents: Real-time data submission to the Tax and Customs Authority of Portugal.

Implementation Timeline

• 2009: Portugal was the first country to implement the OECD’s Standard Audit File for Tax.
• 2021: Non-resident businesses with a Portuguese VAT number were required to use certified invoicing software.
• 2023: Mandatory monthly SAF-T Billing submissions for non-resident businesses.
• 2024: Further delay in the implementation of annual SAF-T Accounting reporting, now due from 2026.
• 2025: Accounting SAF-T becomes mandatory annually, with the first report due in 2026.

Important Notes

• SAF-T Portugal is a mandatory requirement for all income taxpayers, including resident and non-resident businesses.
• The system requires files to be generated in specific formats containing detailed information regarding commercial transactions.
• The information provided does not constitute legal, tax, or management advice and does not replace individual advice.

Advantages of using axsolutions’ SAF-T module:

• no adjustments in standard AX
• all requirements in SAF-T are supported with all 19 data areas
  
• option to export and import setup to spreadsheets for easier maintenance
• optimized for exporting large amounts of data
• file size control (supports splitting into multiple files up to the 2GB limit)
  
• simple user interface in Dynamics AX that the user knows
• continuous maintenance so that the module supports applicable legal requirements
• experience with over 60 running installations with auditor audit by most leading Norwegian auditors